Dear Friends,
Wishing all safe and happy holidays and HAPPY NEW YEAR!
Thank you for reporting intrusive aircraft, signing our petition to reduce aircraft noise over Palo Alto and neighboring communities, and for help engaging elected officials to address our concerns!
With new federal leadership at the helm in offices like the Council of Environmental Quality, EPA, Health and Human Services, we hope to have new resources to help correct practices and policies to better address aviation noise and emissions. Our challenges with the formidable Nextgen Advisory Committee, which receives the highest levels of FAA leadership attention, are not small as they have been charging ahead on their priority projects with no regard to groundlings. Among the NAC’s priorities is GBAS at SFO.
While GBAS has been pitched by SFO as a project to reduce noise for communities near arrival paths - from the information received so far, we are concerned about how GBAS can exacerbate the unresolved problems from Nextgen. It’s not the equipment component that is our concern, which include four receivers and one broadcast system by Honeywell that provide enhanced navigational information for arriving flights, but how the entire system will be used and the resulting impact on groundlings and our environment.
How GBAS will be used is determined by various elements starting with instrument flight procedures development. Per FAA, IFP requirements include “satisfaction of instrument approach procedure prerequisites, collection of airport land survey data, collection of airport data, and satisfaction of an initial environmental review.” Once the FAA publishes GBAS procedures, called “GLS,” pilots can request these procedures to land planes in ways never done before, such as in conditions with zero visibility or during fog events, resulting in an increase in impacts to all communities near arrival flight paths during what otherwise would be lulls in air activity.
We encourage all Santa Clara and Santa Cruz residents to add your questions and comments that are not on our list below, or to reinforce any of the points that we have made, and send to [email protected].
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Response to SCSC's solicitation
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Dear SCSC Roundtable,
In response to your recent communication about GBAS, we applaud your efforts to get clarification from SFO about their project. We remind you that we have sent GBAS-specific questions to you, SFO, and the City of Palo Alto for follow up; these have not been answered and we reiterate them in our questions below.
Of grave concern is the potential for new precision technologies like GBAS to further negatively impact the health and wellbeing of people who are affected by the unresolved problems of Nextgen. We are alarmed that the FAA has been absent from any community involvement on GBAS as the FAA develops GLS procedures. FAA’s absence is contrary to all we have heard from the FAA since 2018 when they launched a Community Involvement Performance Based Navigation (PBN) Desk Guide and FAA's representations to you that roundtables have a say in PBN development including that they look to you for what level of community involvement to perform.
As we've learned with PIRAT, getting public disclosures after procedures are published is nearly impossible. Thus the time for ensuring fair disclosure of GBAS’ estimated impacts is now.
As we respond to your request, please note that we have many more questions for the FAA about environmental review and FAA community involvement, and ask you to please organize a review of these with the FAA.
At this time, per your request, we provide questions for your outreach to SFO.
Questions:
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Please ask SFO to substantiate the information they shared with the SFO Roundtable in November 2020 that the GLS procedures listed in FAA’s “IFP Production Plan” with a scheduled publication date of October 7, 2021 on the IFP Gateway were issued a CATEX in 2018 based on the sole criteria of it being an “overlay.” If a CATEX has been published, does SFO have a copy?
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We would like to know how SFO informed the FAA's decision to not consider anything but SFO’s explanation of an “overlay” for the CATEX if it is verified. Per FAA Order 1050.1F, “overlay” is on a list of FAA categorical exclusions that states: “An action included within this list of categorically excluded actions is not automatically exempted from environmental review under NEPA. The responsible FAA official must also review Paragraph 5-2, Extraordinary Circumstances, before finalizing a decision to categorically exclude a proposed action.” Was there nothing more that SFO provided but “overlay” that led to the FAA's determination?
- Did SFO do any of their own impact estimates analysis? If so, what methodology do they use? Their presentations to the roundtables have analysis of only one aircraft, one flight, and a metric that the FAA does not use for NEPA reviews. What assumptions are they making for their project? Is an increase in SFO’s capacity from GLS considered? Or the ability to land planes during fog thus increasing impacts to communities? Or the potential for concentration and increased vectoring?
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SFO has presented that they can control GBAS so that if it causes harm they won’t use it. While the Honeywell equipment is financed by SFO, the GLS procedures are the FAA’s and part of a national infrastructure project; see NAC powerpoint Item 37 Page 54 (the NAC was asked to list their top priorities from the IFP gateway which has thousands of procedures and SFO GLS is among the 48 chosen by the NAC). Therefore, once the GLS publication/switch goes “on” it’s part of national infrastructure. What agreement would assure that SFO does not use GBAS if it causes harm and who would define harm? SFO and FAA have dismissed an agreement they made in 2000 with Congresswoman Anna Eshoo to maintain SFO arrivals above 5000 feet near the waypoint MENLO now SIDBY; what assurances can we count on for agreements involving FAA and SFO beyond casual comments?
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Last but not least, these are our GBAS Questions to SFO submitted to Mr. Daniel Lee at SFO [email protected], per SFO’s request after an SFO GBAS presentation in Palo Alto in October 2018. As an update, regarding the question about 2012 CATEX legislation, we have sufficient confirmation now in 2020 that 2012 CATEX legislation has never been applied and is probably not applicable to GLS unless SFO has other information. We will reserve our questions on this matter for FAA.
Thank you,
Sky Posse Palo Alto
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SPREAD THE WORD
Ask neighbors to JOIN OUR CALLS TO ACTION and to get updates by sending "SUBSCRIBE" to [email protected]
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Assess alternative waypoints to reduce concentration and "Fly at Higher Altitudes!"
- Eliminate low altitude night flights
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Need new Technical and Social Management Teams to do Metroplex re-design.
Eliminating low altitude night traffic should be the easiest task for FAA because there is no traffic congestion at night. Assessments of alternatives using the right tools is also long overdue.
New concerns have also developed in the six years since Nextgen began. As we go forward, much of what we need is within the power of local and regional officials to help accomplish.
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MOST IMPORTANT
Report intrusive jet noise!
The number of reporters matters (enlist neighbors who are bothered by intrusive jet noise to report!)
Use any of these methods:
SFO PHONE 650.821.4736/Toll free 877.206.8290.
ONLINE:
Complaint Option with IFTTT App - You can make your own noise complaint button with smart phone app see instructions here. The app sends the complaints to [email protected] (or the noise office email address of the airport of your choice) with the message body including name, address, time and noise type. You may also want to try programmable button with it.
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Thank you!
Sky Posse Palo Alto
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